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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Borner v. Autry

This case interprets Tennessee Code Annotated section 24-5-113(a), which establishes a rebuttable presumption for the necessity and reasonableness of medical bills totaling $4,000 or less, if itemized and attached to a complaint. The Tennessee Supreme Court clarified that this presumption applies to the total amount of bills itemized and attached, not the total medical expenses incurred. However, the court ruled that plaintiffs cannot invoke this presumption if they have redacted medical bills to fall within the $4,000 limit, as redacted documents are not considered true "copies" of original bills. Consequently, the plaintiffs, Helen and Lekesa Borner, who had altered Dr. Heilman's medical bills, were deemed ineligible for the statutory presumption. The Court of Appeals' judgment was affirmed in part and reversed in part, remanding the case for further proceedings.

Medical Bill PresumptionStatutory InterpretationEvidence RulesPersonal Injury LawAutomobile AccidentPleading RequirementsRedaction of DocumentsBurden of ProofTennessee Supreme CourtAppellate Procedure
References
10
Case No. ADJ9468922
Regular
Aug 11, 2025

THEODORE DAVIS vs. CITY OF MODESTO, ATHENS ADMINISTRATORS CONCORD

The applicant, Theodore Davis, a firefighter for 36 years, developed prostate cancer which was denied by the City of Modesto. The case revolves around the application of Labor Code section 3212.1, which establishes a rebuttable presumption of compensability for cancer in firefighters. The Workers' Compensation Judge found that the medical opinion of PQME Dr. Allems, which stated that prostate cancer was not industrially caused in firefighters, was based on an incorrect legal theory and contained inconsistencies. Consequently, this opinion was deemed not substantial evidence to rebut the statutory presumption, leading to the denial of the Petition for Reconsideration by the Appeals Board.

Workers' Compensation Appeals BoardPetition for ReconsiderationLabor Code Section 5909Electronic Adjudication Management System (EAMS)Industrial CausationAOE/COELabor Code Section 3600Cancer PresumptionLabor Code Section 3212.1Firefighter
References
9
Case No. MISSING
Regular Panel Decision

Claim of Booker v. Intermagnetics General Corp.

Claimant fainted at her workstation, suffering a traumatic head injury. She filed for workers' compensation, which the employer and carrier controverted. A Workers' Compensation Law Judge determined the injury arose out of and in the course of employment, applying the Workers' Compensation Law § 21 (1) presumption, and found the carrier's rebuttal evidence speculative. The Workers' Compensation Board affirmed this decision. The Appellate Division affirmed the Board's decision, concluding that the carrier's medical expert's opinion, attributing the collapse to metabolic acidosis from prior alcohol/substance abuse, was insufficient to overcome the statutory presumption, especially given evidence of 18 months of sobriety.

Workers' Compensation LawStatutory PresumptionAccidental InjuryArising Out of EmploymentCourse of EmploymentUnwitnessed AccidentEmployer LiabilityCarrier RebuttalMedical Expert TestimonyMetabolic Acidosis
References
8
Case No. MISSING
Regular Panel Decision

Walters v. American States Insurance Co.

Justice, an employee of Lamport, was found dead, and Walters, the claimant, sought workers' compensation. American States, the insurer, argued that Walters failed to negate a statutory exclusion for injuries caused by a third person for personal reasons. The court of appeals sided with American States, placing the burden on Walters. This concurring opinion agrees with the majority's result that Walters failed to meet the burden. However, Justice McGee argues that Walters should be entitled to a rebuttable presumption that the assailant acted for reasons other than personal ones, especially when the cause of death is an intentional act of an unknown assailant and motives are unclear, and the employee was found dead within the scope of employment. This presumption, McGee argues, aligns with a liberal construction of the Workers' Compensation Act.

Workers' CompensationStatutory ExclusionBurden of ProofLegal PresumptionUnexplained DeathIntentional InjuryCourse of EmploymentCausationCircumstantial EvidenceThird-Party Injury
References
13
Case No. MISSING
Regular Panel Decision

Interstate Mechanical Contractors, Inc. v. McIntosh

Billy McIntosh sustained a severe hand injury while operating a power roller machine at Interstate Mechanical Contractors, Inc. He subsequently tested positive for marijuana, triggering a statutory presumption under Tennessee's Drug-Free Workplace Act that his drug use proximately caused the injury. The trial court, however, found that McIntosh successfully rebutted this presumption, concluding that the injury was proximately caused by an inexperienced coworker engaging the machine, not McIntosh's impaired reaction time. Interstate Mechanical Contractors, Inc. appealed this decision, arguing the trial court erred in its application of the statutory presumption and causation. The appellate court affirmed the trial court's judgment, upholding the finding that McIntosh had successfully rebutted the presumption.

References
10
Case No. MISSING
Regular Panel Decision

Claim of Musicus v. Broadway Pastry Shop, Inc.

A billing clerk (claimant) suffered a fall and injury to her left arm and shoulder at work on April 10, 1978. Despite a history of high blood pressure and dizzy spells at home, the claimant denied such incidents at work, and a co-worker could not explain the fall. The Workers’ Compensation Board found the accident compensable, relying on the statutory presumption of Workers’ Compensation Law § 21. The appeal contended the fall was idiopathic and thus the presumption should not apply. The court affirmed the Board's decision, concurring that no substantial evidence rebutted the statutory presumption, as the injury occurred within the course of employment.

Workers' CompensationIdiopathic FallStatutory PresumptionCourse of EmploymentInjuryBilling ClerkHigh Blood PressureDizzy SpellsAppealCompensability
References
3
Case No. MISSING
Regular Panel Decision

Coffey v. City of Knoxville

A police officer employed by the City of Knoxville suffered a stroke and sought workers' compensation benefits, relying on a statutory presumption for law enforcement officers with hypertension or heart disease. The trial court denied coverage, finding the presumption rebutted. On appeal, the Special Workers’ Compensation Appeals Panel reviewed the medical expert testimony from both treating physicians and cardiologists. The panel concluded that the defendant, City of Knoxville, failed to overcome the statutory presumption with competent medical evidence. Consequently, the panel reversed the trial court's judgment and remanded the case for further proceedings to determine the plaintiff's disability and benefits under the Workers’ Compensation Act.

Workers' CompensationStrokeHypertensionPolice OfficerStatutory PresumptionMedical Expert TestimonyCausationReversalRemandTennessee Law
References
6
Case No. MISSING
Regular Panel Decision

Bohanan v. City of Knoxville

Arthur M. Bohanan, a retired Knoxville police officer, sought workers' compensation benefits for hypertension, alleging it was caused by his employment and relying on a statutory presumption for law enforcement officers. The City of Knoxville, the employer, presented medical evidence through Dr. Roseman, who testified that Bohanan's hypertension was due to factors like weight gain and a sedentary lifestyle, effectively rebutting the statutory presumption. The trial court initially ruled in favor of Bohanan, awarding permanent partial disability. However, the appellate court reversed this decision, finding that the employer successfully rebutted the presumption and Bohanan failed to prove a job-related causal connection for his hypertension.

Workers' CompensationHypertensionLaw EnforcementStatutory PresumptionCausationMedical EvidencePermanent Partial DisabilityRebuttalPolice OfficerTennessee Law
References
5
Case No. W2018-01353-COA-R3-CV
Regular Panel Decision
Jan 31, 2020

Pamela Pryor v. City of Memphis

This case involves Pamela Pryor's appeal against the City of Memphis' denial of On-the-Job-Injury (OJI) benefits after her firefighter husband's death. The City denied the claim due to the absence of an autopsy report, a requirement of its OJI policy. The trial court reversed an Administrative Law Judge's decision, finding the City's policy conflicted with Tennessee Code Annotated section 7-51-201, which establishes a statutory presumption for firefighters' deaths caused by hypertension or heart disease occurring in the line of duty. The Court of Appeals affirmed the trial court's decision, deeming the City's autopsy requirement null and void for creating an additional burden on the claimant and usurping the statutory presumption. The case has been remanded to the ALJ for a new hearing applying the statutory burden-shifting analysis without the invalidated policy.

OJI benefitsFirefighter presumptionStatutory conflictAutopsy requirementBurden of proofAdministrative Law JudgeChancery CourtAppellate reviewRemedial statutesHypertension
References
26
Case No. MISSING
Regular Panel Decision

Stone v. City of McMinnville

Charles Stone, a McMinnville police officer, suffered a heart attack and sought workers' compensation benefits, relying on a statutory presumption that heart disease for law enforcement officers is an employment-related injury. The City of McMinnville challenged this, presenting medical evidence from three physicians who attributed Stone's heart attack to lifestyle factors such as high cholesterol, hypertension, and smoking, rather than job stress. While Stone initially established a prima facie case with the statutory presumption, the court found that the competent medical evidence successfully rebutted this presumption. Consequently, Stone failed to prove a direct causal link between his employment and his heart attack, as no specific physical or emotional event precipitated the condition. Therefore, the Special Workers’ Compensation Appeals Panel's decision, which reversed the trial court's award of benefits and dismissed the suit, was affirmed.

Workers' CompensationHeart AttackPolice OfficerCausationStatutory PresumptionRebuttalMedical EvidenceLifestyle FactorsEmployment-related InjuryTennessee Law
References
15
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